2023 (8) TMI 442

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.... u/s 271(1)(c) of Income Tax Act, therefore the Penalty order and also Appellate order are bad in Law, against provisions of Income Tax Act and are against facts and circumstances of the case. 2. The National Faceless Appeal Centre has grossly erred in Law and on Rs. 1,12,220/- facts of the case in confirming the penalty imposed by Assessing Officer of Rs. 112220 u/s 271(1)(c) of Income Tax Act, therefore the Appellate Order is bad in Law, against provisions of Income Tax Act and is against facts and circumstances of the case. 3. The assessee craves leave to amend, add or modify any grounds of appeal before the disposal of the appeal." 3. The present appeal has been preferred through Legal Heir of Late Smt. Sangita Verma. 4. Facts giv....

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.... the explanation on the provision of section 271(1)(c) of the Act. To buttress the contention that under these facts, no penalty can be imposed u/s 271(1)(c) of the Act to the assessee. Further, he submitted that the assessee has proved his bonafide in terms of section 271(1)(c) of the Act. 8. On the other hand, Ld. Sr. DR opposed these submissions and supported the orders of the authorities below. 9. I have heard Ld. Authorized Representatives of the parties and perused the material available on record and gone through the orders of the authorities below. Looking to the totality of the facts of the present case, the assessment was made ex-parte/best judgement assessment under the provision of section 144 of the Act as the assessee was no....